July 31, 2015

In response to the letter from the FAA, Brenda Robeson, Program Analyst, Airmen and Airspace Rules 

Division: Cannot Process Request

Docket number FAA-2015-0921

Question 1: The reason why granting the request would be in the public interest, that is, how it would 

benefit the public as a whole.

Answer: 

Granting this exemption to Flying Tigers Aviation will benefit the public directly in several ways. Flying 

Tigers Aviation provides contract workforce training for Louisiana Delta College in the areas of aviation 

education, agricultural aerial application, and public service/emergency response. All of the areas are 

focused on support to the rural NE Louisiana and Mississippi Delta region. The demographics and 

geographies of the Delta are captured in the areas requested under this exemption.

Education:

By granting this exemption, Flying Tigers Aviation will be able to train competent operators through the 

Louisiana Delta College work force training program for many drone applications. These operators will 

use UAS in ways that will increase safety to ground crews in dangerous or disaster situations, help to 

increase crop yields, and reduce pollution from fertilizers and pesticides as well as provide wildlife 

management support. The goal of UAs training is to realize more precise agricultural use of chemicals to 

improve crop yields while reducing any negative impact on the environment. Pilot and sensor 

operators trained through this program will be able to locate problem areas and target them directly, 

rather than blanket spraying entire fields with chemicals. These operators will then have the advantage 

of being qualified to enter a new sector in the labor force of the US economy. 

Agriculture:

UAS can be used in ways that allow a targeted approach to the application of treatments for many 

problems that impact the growth of crops. The use of UAS is being validated daily for its ability to

increase the efficiency of farmers through crop surveillance and precise chemical application. This 

directly translates into higher production rates of food for the US and other nations. This “precision 

agriculture” approach also translates into fewer pesticides, herbicides, and fertilizers being released into 

the environment. This can have a trickle-down effect of reducing pollution in rivers and lakes, which has 

a positive impact on the aquatic life in those bodies of water. 

Public Service/Emergency Response:

UAS can be used in response to disasters such as hurricanes, floods, earthquakes and others. They can 

create a safer approach to information gathering for the crews deployed to these disaster areas, and 

provide them with a means to make better decisions about how they will save lives, while not risking 
their own. One example would be an earthquake situation where there is a factory with dangerous 

chemicals that may be on the verge of collapse. A UAS can be deployed to survey the damage and to 

scout a safe route into the structure, allowing rescue crews to reach victims in a quick and much safer 

manner than if they did not have an aerial view of the scene. In the Delta region there are routine 

natural disaster events such as flooding, tornadoes and hurricanes where the UAS can provide 

immediate disaster response support in ways that will save lives and enhance ground unit effectiveness.

It is the intent of Flying Tigers Aviation to approach these areas and others in a way that will improve the 

quality of life and the safety of everyone involved and all that could be affected by the results of the 

operation of UAS.

Question 2: The reasons why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which you seek an 

exemption.

Flying Tigers Aviation is a professional company which holds safety to a very high standard. The DAx8 

will be operated in the same manner as a full size aircraft. Below are some examples of the safety 

considerations that affect the operation of the DAx8.

-The safety of full size air traffic is a top concern. Communication with full size aircraft for de-confliction 

will protect passengers and pilots of full size aircraft by keeping the UAS out of airspace occupied by full 

size aircraft, and to notify full size aircraft of the operations so that they can avoid the UAS operation 

area.

-Safety of bystanders and operators is also a top priority. Airspace will be cleared, and overflight of 

people will be avoided. Bystanders will be notified of the use of the UAS and will be instructed by the 

flight crew so that they are aware of any precautions necessary to ensure safe cooperation between the 

UAS and people on the ground.

-Pilots will be trained by Drone America or Flying Tigers Aviation in the specific operations of the DAx8. 

They will be validated 

-The use of checklists, good planning practices, and attention to detail will ensure safe operations. 

-The aircraft will not be operated outside of the manufacturers specified limitations.

-A preflight inspection is performed prior to every flight, which is also part of a continual maintenance 

-The aircraft will be operated by licensed pilots who have already been trained in manned aerial 

application operations over the same exemption areas.

Mr. Lawrence L. Rolfs

Flying Tigers Aviation, LLC

P.O. Box 238

Oak Ridge, LA 71264